Case Digest (G.R. No. L-18716)
Facts:
- Clemente Sumcad is the petitioner against the Court of Industrial Relations and the Philippine Marine Officers Guild.
- On May 31, 1955, the Guild was certified as the exclusive representative of marine officers and engineers of William Lines, Inc.
- A collective bargaining agreement was signed on December 30, 1957, which included a closed-shop provision requiring all marine officers and engineers to be Union members.
- The agreement mandated immediate dismissal for any officer or engineer deemed not in good standing by the Union.
- Sumcad, the Master of a vessel, refused to join the Union due to legal restrictions against joining a labor organization of his subordinates.
- The Union sought his dismissal, leading to a notice from the Company on February 3, 1958, demanding Union affiliation within 24 hours.
- Sumcad filed a complaint for a preliminary injunction to prevent his dismissal, but the court dismissed his case.
- After his dismissal, Sumcad filed a complaint for unfair labor practice against the Company and the Union.
- The Union's motion to dismiss was granted after Sumcad and the Company reached a settlement, which the court approved on May 27, 1961.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of Clemente Sumcad, setting aside the orders of the Court of Industrial Relations.
- The case was remanded for fur...(Unlock)
Ratio:
- The Supreme Court's decision was based on the Industrial Peace Act, which allows employees to join any labor organization of their choice.
- The Court highlighted that coercing employees in exercising their rights constitutes an unfair labor practice under Section 4 of the Act.
- It reasoned that whether or not Sumcad was cov...continue reading
Case Digest (G.R. No. L-18716)
Facts:
The case involves Clemente Sumcad as the petitioner and the Court of Industrial Relations along with the Philippine Marine Officers Guild as the respondents. The events leading to this case began on May 31, 1955, when the Philippine Marine Officers Guild was certified as the exclusive representative of all marine officers and engineers of William Lines, Inc., a domestic corporation engaged in coastwise shipping. On December 30, 1957, the Company and the Union entered into a collective bargaining agreement that included a closed-shop provision, mandating that all marine officers and engineers must be members in good standing of the Union as a condition of their employment. The agreement stipulated that if the Union notified the Company that an officer or engineer was no longer in good standing, the Company was required to dismiss that individual immediately.
Clemente Sumcad, who was the Master of one of the vessels of the Company, refused to join the Union, citing legal restrictions that prevented him from joining a labor organization of his subordinates. Consequently, the Union sought his dismissal. On February 3, 1958, the Company issued a written notice to Sumcad, requiring him to affiliate with the Union within twenty-four hours or face dismissal. In response, Sumcad filed a complaint in the Court of First Instance of Cebu, seeking a writ of preliminary injunction to prevent his dismissal. The Union intervened and moved to dismiss the complaint, arguing that the court lacked jurisdiction over the matter. The court granted the Union's motion, leading to the dismissa...